Dear Mark Denittis, Why Did You Close Il Mondo Vecchio? - An Open Letter

Dear Mark,
I’ve been considering writing a post or open letter regarding the soon-to-close Il Mondo Vecchio. While I simply could have written a private message, I believe that my questions and concerns are shared by others who will benefit from a public airing.

Let me start by saying, although I do not know you beyond some Facebook exchanges, I have tried many of your products andI believe that the value they add to the overall quality of salumi products in this country is immeasurable. It’s undeniable that you’ve had a positive impact on the community here in the Denver-area, even supporting local farms and producers publicly. A rising tide raises all ships, and anything that gets people eating salumi that isn’t mass-produced is fine with me.

But what stumps me is how you’ve handled the recent closing of your company. There are a number of holes I see based on my experience and knowledge - perhaps some transparency that could be provided by you. My main issue comes from the way in which you seem to have been a victim ofthe USDA regulations.

You have been open for three years now, and according to what I’ve read, have worked closely with the USDA from the start, but do not wish to pursue a “challenge” to the USDA, in which you provide proof as to your method of production being safe. All this being said, out here in Boulder County, where the evangelical foodies seem to congregate with all of their ideals and misinformation in tow, I feel as though the posture you have taken may be doing a great disservice to the honesty and transparency within the world of salumi-making.

The points I want to address are:

Your refusal to use nitrate when by USDA regulations you are required to use a form of nitrate unless you provide proof as to your methods being sound.

Your rejectionof starter cultures and how that relates to product safety.

The salt volume requirements set forth by the USDA can also be challenged by providing proof of sound methods

3) The idea that USDA Challenges can be provided to support your methods and procedures.

4) The integrity of Old World Methods and how the regulations affect them.

5) Your decision to close vs. the USDA forcing you to close

I have followed these articles about Il Mondo Vecchio’s closing, and would like to address the following:

Having some experience with curing and the science behind it, I have been compelled to research the subject even further since the closing of Il Mondo Vecchio was announced. I have had discussions with people in the area who love your products and fear the vilified nitrates even without appearing to understand why they fear them. While I do not alwaysagree with the methodology and means of the USDA, I understand that manyAmericans are mistrusting of cured meat and so the USDA has taken measures to protect the masses.The recent interest in pork and cured products is fantastic, and we all hope to educate potential consumers about the benefits of local food, small-scale production, and artisan traditions. The USDA is tasked with protecting consumers— maybe not the way we would always like, but that is their job nonetheless. We have the choice to work with them, or not at all.

“Il Mondo Vecchio essentially hit an impasse. They could either change their methods to a process that has been validated by the USDA such as fermenting (cooking the product) or adding nitrites, nitrates, acids or copious amounts of salt, all resulting in what IMV believes to be an
inferior product or stop production.“

That said, I don’t know of a more hotly-debated topic within the world of salumi-making and eating than the use of nitrates in cured meat. The USDA’s requirement for nitrates seems to be a common point of contention amongst many salumi makers when it comes to maintaining integrity of process. (Was this the case for your business?) Me, I’m unsure as to why there is such resistance to a naturally occurring compound.

Nitrates have been around for hundreds of years and are naturally-existing within salt mines, within greens such as celery, spinach and beetroots and even within your saliva. Studies have also begun to emerge that are showing nitrates as an antioxidant and potentially beneficial.

The other thing you fail to mention in any of these articles is that the amount set by the USDA as a maximum is still nominal. If using Instacure 2, it’s 6.25 % sodium nitrite and 1% sodium nitrate, resulting in 7.25% total nitrates per the total weight of Instacure added. The USDA has a maximum of 625 parts per million (ppm) nitrates, which at the end of the day is .0625% of total weight of meat product.

1lb of raw meat/fat (453 grams) would be allowed a maximum of .0625% nitrates (625ppm). Before drying, you would have a level of .283 grams of nitrates. During drying, this converts almost entirely to nitric oxide leaving you with, at most, .002 grams of nitrate.

A single serving of greens with naturally-occurring nitrates have significantly higher levels than that in a single serving. Nitrates at that volume, in my experience, do help to retain color, but impart little to no flavor, especially in heavily seasoned products such as your own.

There have been no studies since 1972 that have proven any risk with regards to nitrates, and even that study refers to ingesting the amount of two tablespoons of straight nitrates. For what it’s worth, you can’t even easily purchase straight nitrates, as both cure types (#1 and #2) are composed of 6.25% nitrites and a combination of 6.25% nitrites and 1% nitrates respectively. The rest of the makeup of the cures is salt.

A 155lb man would need to consume approximately 14lbs of raw product intended to be dry-cured in one sitting. Given the reduction of nitrates to nitric oxide during the drying process, he would then need to eat a whopping 35 – 45 lbs of the same finished product to reach even potential “lethal” dose of nitrates. And tell me, who could eat even one pound of cured meat in a single sitting? It’s virtually impossible to ingest anywhere near a harmful amount of nitrates, let alone a lethal dose.

In short, if you had a plate of 1/4lb of salumi, with a side of potatoes and spinach, there would be more nitrates in the spinach and potatoes than the entire serving of salumi.

I’m sure we can agree that this is purely ground-meat salumi where nitrates are absolutely critical. Given that whole muscles do not share the same air pocket risk, I see no issue with not using nitrates there, however, it still does not result in a negative affect on the consumer.

The other glaring omission in the articles is the fact that many producers use converted celery or cherry juice powder in their uncured products. While I am not sure whether or not you use plant based nitrates, the use of these products does in fact add nitrates into the meat and therefore trace amounts of nitrates are found within the finished product as well. There are several producers in this country providing a high quality product through the use converted celery juice, with the end result still being the addition of nitrates

This is misleading or at the very least confusing to consumers who are trying to understand the nature of their purchases and the differences between cured and uncured meats. It should be noted that cherry juice powder is a nitrate-reductant when combined with celery juice powder. It does not represent a substitute for nitrates, but is used purely for the maintenance of meat color.

To my knowledge, during the process of creating a HACCP (Hazard Analysis & Critical Control Points) plan, all aspects of product creation and sanitary maintenance must be outlined in detail. From the regulations I see, you have two choices:

Use an approved nitrates source

Provide adequate proof that your methods are in fact sound

You maintain that no synthetic nitrates are added, but do you use alternative source of nitrates? If you do, in fact, use converted celery juice powder, why is that not mentioned in any of your many interviews? Is it that you do not trust in the soundness of your production methods? Have you spent so much time stumping against the use of nitrates that you are unwilling to level with consumers about the specific ingredients their salumi actually contains? This seems to be the single-most confusing piece of the cured meats puzzle for consumers, and it’s no wonder. Nor is it the fault of any single person. There is a vast and wonderful opportunity at hand for education about curing to the general public. People want to learn more about this fascinating and ancient tradition of preservation. That can only be achieved through transparency of practice

“ Our name literally means ‘Old World,” DeNittis told me by phone. And how did they cure meat back in the old world? With a discrete, short list of ingredients: “Sea salt, meat, quality spices, and time.”

You mention often the lack of nitrates in “Old World Methods” not just on your website and within emails and articles. Is there historic evidence that proves this as fact?In Europe, many large-scale hundred year old makers use saltpeter (potassium nitrate – KNO3) Saltpeter has been banned by the USDA for proven health effects, such as impotence. Although this has been up for some debate recently, nothing conclusive has been published to my knowledge. Saltpeter remains in use in Europe, but is banned in the U.S.

Many “Old World” methods used far less salt then what science has shown to be necessary (2% minimum), and others use far more. Hell, in many “Old Word Methods”, they don’t even measure most ingredients and go by taste and appearance rather than weight. My Nonna used to eat raw pork to check flavor, something no one in modern day salumi making would dare.

2) Starter Cultures

On your site, you also mention that there is no use of starter cultures. How do you ensure the proper drop in pH to achieve the necessary decrease in water activity that is required to halt the growth of pathogens? Do you measure pH to ensure a Log7 (99.99999%) reduction of fecal coliform? Everything I’ve read dictates that a starter culture is crucial to the prevention of unwanted bacteria, as well as to break down any nitrates present into nitric oxide. Without the use of cultures, it’s been my experience that there is significant wasted product due to lack of consistency in the end product. Furthermore, in European traditions, there is often a practice employed that when good cultures are discovered, they are scraped from the finished product and inoculated in pieces of wood and/or cloth to ensure that they consistently present during the drying process. So is your object to only to purchased starter cultures” or do you also oppose starter cultures made by traditional “Old World” methods?

“Il Mondo Vecchio essentially hit an impasse. They could either change their methods to a process that has been validated by the USDA such as fermenting (cooking the product) or adding nitrites, nitrates, acids or copious amounts of salt, all resulting in what IMV believes to be an inferior product or stop production.“

In the above quote from the press release, you say that fermentation is the equivalent of “cooking the product “, which is entirely not true. Fermenting is done at temperatures between 66 – 75 degrees and a humidity of approximately 90%. The process does not produce enough heat to raise the temp enough to cook or kill bacteria. The process of fermentation is simply the production of lactic acid within the meat to produce the desired acidity and sourness by increasing the amount of lactic acid producing bacteria.

3) USDA Challenges

“One option the USDA did make available to Il Mondo Vecchio, DeNittis tells me, was to pay $7,000 to conduct a “challenge study”—essentially a test that would prove the USDA wrong. But even that might not be enough for the agency.

“You can do the challenge study,” DeNittis says the agency told him, “but we may not accept the results."

In the articles and mass emails sent, you state that USDA challenges were costly and time-consuming and thus weren’t something you were going to pursue. You list a figure of $7,000 as the cost. While this is not a small sum for most folks, as a producer with three years of business at stake and presumably millions of dollars invested, it seems a small sum to pay. I would think at least a single attempt would be made to protect your methods, product integrity and your business. There have been quite a few challenges that have been accepted, one more notably being Salumeria Biellese in NYC, which submitted their challenge to the USDA and won (They don’t use nitrates either, so it is not impossible to win). I struggle to understand not even a single attempt on your part, especially with as detailed a records you reference in the articles, as well as confidence in your methods.

“ In a recent audit of their procedures, the USDA required Il Mondo Vecchio to provide a scientific study or additional support documentation to further prove the validity of their procedures or change their procedures to fit a standard USDA production method. Because Il Mondo Vecchio was essentially producing salumi in a manner that no one had previously successfully validated under the USDA and because the USDA is not set up for artisanal producers, the USDA regulators put the burden on Il Mondo Vecchio to prove the procedures were in compliance. “

As I understand the law, there are opportunities to change the level of nitrates and/or salt to be used for dry curing from the defaults provided by the USDA. The USDA does however require you to provide adequate proof that your process would achieve Log7 (99.99999%) reduction of coliform bacteria. If you can’t prove this with your methods, it opens up the questions:

Are the methods in place in fact adequate and safe?

Why not use nitrates until you can prove your methods through the challenge submission?

With precedents in place, and a clearly loyal customer base, why not challenge? Again, faith and evidence in the safety of the process has clearly been demonstrated in previous cases. (http://www.leaveitbetter.com/blog/the-salumeria-biellese-takes-its-salumi-seriously-sustainably-an/)

4) Salt Volumes

“ Il Mondo Vecchio's website also boasts that it hand crafts salumi from “age old family recipes.” Its products are all natural, “minimally processed, and contain [] no artificial ingredients.” Il Mondo Vecchio even cares about its salt—obtaining “ancient sea salt from Utah (just west over the Rocky Mountains)” and using “the lowest allowable salt content of today’s producers nationally. ”

There is mention in the interviews in contention of the volume of salt required by the USDA. Salt volumes are dictated, as a default, by the USDA, however as stated above, you can absolutely provide them with studies to prove your methods are sound and fundamentally safe against the requirements by USDA regulations. It’s scientifically proven that a minimum of 2% salt is required to produce a safe product. In most of my curing projects, I use anywhere from 2.5 – 3.5%, depending on meat flavor, length of cure, etc. It’s calculated as a percentage so that the product absorbs the exact amount of salt used, creating a product that is safe and able to be eaten without it tasting like a salt lick. This is known as equilibrium curing.

In my experience and reading about “Old World Methods”, weighing the ingredients against the starting product is a rarity, with more common practice being instructions such as - “ as much salt as the meat will hold “ given as directions. Given the proper methods and pH records, why would the amount of salt suddenly become an issue? What percentage of salt were you using?

I think what frustrates me on a whole is that you entered this world with years of meat cutting experience, you knew the wacky world that is USDA regulations and - while it’s no secret they are set up to address large scale production programs – not only have they been who they are well before you opened, frankly, they have improved in process acceptance since then. How can you enter the game knowing the rules, but then complain of the rules after the fact?

5) Being forced to close the doors

There is a nuance in language that I think you need to address. You often frame the closing of your business in the press and to customers in language that suggests your act was heroic i.e. you were throwing your company on the proverbial sword.You continually say in the emails you’ve sent and within the articles, that the USDA forced you to close your doors despite having options to the contrary.

“ After two months of sharing information and collaboration back and forth between Il Mondo Vecchio and the USDA as well as various attempts to modify the production methods, Il Mondo Vecchio has determined that the impact of the regulatory requirements on dry cured sausage products was detrimental to the quality of the product and therefore, Mark and Gennaro are forced to close the doors. “

It's a small detail, certainly, but it is important, as you did have options. With such strong words and opinions against the USDA, are you concerned at all aboutthe spotlight you’re putting yourself and your future endeavors under? It seems that publicly bashing the USDA would work against your favor, no?

My hope that as an educator you take the opportunity and spotlight you have not to say “woe is me”, but rather to educate the consumers and prospective producers alike about what it takes to work with the USDA, transparency in your methods and the details in proof you have to support your methods and decisions. We have some of the most food-aware people in the country in this area of Colorado, many with very incorrect information; I’d hate to see that continue with the closing of a beloved shop.